Courts: ITAT Mumbai
5,841 articlesIncome Tax

Income Tax
Arm’s length price should be based on the functional and asset profile of the company
Income Tax

Income Tax
Prescribed methods to be followed for ALP determination and interest on outstanding trade balances not the same as interest on loan
Income Tax

Income Tax
Provision made for bad and doubtful debts to be included in the ‘Book Profit’ for the purpose of MAT
Income Tax

Income Tax
No Penalty for bonafide difference of opinion in selection of transfer pricing method
Income Tax

Income Tax
If thin capitalization rules are not in the domestic law/Treaty, there can be not be artificial disallowance of interest paid on borrowings
Income Tax

Income Tax
National Aviation Co. of India Vs. DCIT (ITAT Mumbai)
Income Tax

Income Tax
Taxpayer can remit monies abroad without tax deduction if it is of opinion that remittance is wholly exempt from tax
Income Tax

Income Tax
Payment received by taxpayer for sale of shrink wrapped software is not royalty under Article 12(3) of the India-USA tax treaty
Income Tax

Income Tax
HC requests ITAT President to make it compulsory for assessees to amend Form 36 for change of address instead of merely intimating vide letter
Income Tax

Income Tax
Higher price paid to AEs accepted as ALP under the CUP Method, provided there is sufficient economic and commercial justification evidencing the same
Income Tax

Income Tax
No disallowance u/s. 40(a)(ia) where payments made were apparently less than Rs. 20,000 each and to each party less than Rs. 50,000 per year, as per t
Income Tax

Income Tax
Mere existence of subsidiary company in India does not constitute subsidiary company as PE of Parent company
Income Tax

Income Tax
Payment made to USA entities cannot be disallowed on account of non deduction of tax at source
Income Tax

Income Tax
